Professional indemnity explained

General liability vs professional liability: the UK equivalents

Reviewed by the Apex broking team · Last reviewed 2026-10-31

General liability is the US term for cover against injury and property damage claims, while professional liability covers claims that your advice or service caused financial loss. In the UK these are usually public and products liability and professional indemnity.

Part of: Professional indemnity insurance

In short

General liability (often called CGL in the US) broadly maps to UK public liability and products liability insurance, which cover third party injury and property damage. Professional liability, also called errors and omissions (E&O), maps to UK professional indemnity insurance, which covers claims that negligent advice, design or services caused financial loss. Employers’ liability is a separate UK cover, compulsory for most employers. When a US client asks for CGL and E&O certificates, a UK business can usually satisfy the request with its public liability and PI policies, provided limits, jurisdiction and additional insured wording are checked.

The short answer

The US and UK markets use different names for broadly similar covers. A UK business asked for "general liability" and "professional liability" is usually being asked for public and products liability and professional indemnity insurance. The labels differ, but so do some of the details, which is why a straight swap is not always enough.

The key distinction is the type of harm. General liability responds to physical harm: injury to people and damage to their property. Professional liability responds to financial loss caused by a failure in your professional service, such as a wrong calculation, a missed deadline or bad advice. Our page on PI versus public liability covers the UK side in more depth.

How the terms map

US term	Nearest UK cover	What it usually covers
Commercial general liability (CGL)	Public liability plus products liability	Injury to third parties and damage to their property arising from your business or products
Professional liability or errors and omissions (E&O)	Professional indemnity	Claims that negligent advice, design or services caused a client or third party financial loss
Technology E&O	PI for technology businesses, often combined with cyber	Failures of software or IT services, sometimes with data breach liability
Workers’ compensation and employers’ liability	Employers’ liability	Claims by employees injured or made ill at work
Additional insured endorsement	Indemnity to principals or a named party extension	Extends cover to the client for liability arising from your work

The terminology overlaps further. "Professional liability" is also used in the UK, usually meaning the same thing as PI; see professional liability versus professional indemnity and PI versus E&O.

One structural difference is worth knowing. General liability and UK public liability are commonly written on an occurrence basis: the policy in force when the injury or damage happened responds, even if the claim arrives years later. Professional liability and UK professional indemnity are commonly written on a claims made basis: the policy in force when the claim is first made responds. That is why PI buyers need continuous cover and, when they stop trading, run-off. It also means a certificate for PI says less about past work than a certificate for public liability does, so a careful client will ask about retroactive dates and how long you will keep cover in place after the contract ends.

The legal background in the UK

Different laws sit behind each cover.

Employers’ liability is compulsory for most UK employers under the Employers’ Liability (Compulsory Insurance) Act 1969. The GOV.UK guidance on employers’ liability insurance says cover must be for at least £5 million from an authorised insurer, and that employers can be fined £2,500 for every day they are not properly insured.
Public and products liability are not generally compulsory, but contracts, landlords and venues commonly require them. Products claims may arise under Part I of the Consumer Protection Act 1987, which imposes liability for damage caused by defective products.
Professional indemnity is compulsory for many regulated professions through their regulators. Where it is not, clients often require it. Business contracts for services carry an implied term that the supplier will act with reasonable care and skill under section 13 of the Supply of Goods and Services Act 1982, and breach of that duty is the root of most PI claims.

When a US client asks for CGL and E&O certificates

US procurement teams often send a standard insurance schedule asking for CGL, E&O, auto, umbrella and workers’ compensation, along with a certificate in a US format. A UK supplier can usually respond by:

Mapping each requirement to its UK equivalent and explaining any that do not apply, such as US workers’ compensation for a business with no US staff.
Checking jurisdiction. Many UK policies exclude or limit claims brought in US or Canadian courts. See PI and US jurisdiction and public liability and US jurisdiction.
Checking limits and basis. US schedules may ask for "per occurrence" and "aggregate" limits. UK PI is commonly written on a claims made basis with an each and every claim or aggregate limit, which should be explained rather than misstated.
Handling additional insured requests. Public liability policies can often extend an indemnity to a client. PI is harder, because it protects you against claims by the client. See additional insured endorsements and when a client wants to be added as additional insured.
Supplying evidence. Your broker can usually provide a letter or certificate summarising cover. See ACORD 25 certificates for US clients and what clients can ask to see.

Illustrative examples

These examples are illustrative only and do not describe real cases.

Example 1: the UK software consultancy. A US customer requires CGL and technology E&O. The consultancy holds public liability and PI. The broker confirms both policies extend to work for US clients, with any US jurisdiction limits stated, and provides a certificate summary.
Example 2: the visiting engineer. A UK engineer's site visit causes damage to a client's equipment. That is a public liability matter. A separate allegation that the engineer's design report was wrong would be a PI matter.
Example 3: the hold harmless clause. A US contract requires the supplier to indemnify the client for all losses. Insurance may not cover liability taken on by contract beyond what the law would impose. See hold harmless and indemnity agreements.

Common misunderstandings

"Public liability covers my advice." It usually excludes professional advice and financial loss.
"PI covers someone tripping in my office." That is usually public liability.
"A UK policy covers US claims automatically." Jurisdiction limits often apply.
"General liability covers data breaches." Data and network risks usually sit in a cyber policy, with some liability cover possible under PI.
"Adding the client to my PI is routine." PI insurers are cautious about naming clients, because the client is the most likely claimant.

Apex arranges professional indemnity and liability programmes for UK businesses with US clients; a broker reads every enquiry.

Sources

Frequently asked

What is the UK equivalent of general liability insurance?

Public liability and products liability insurance. Together they broadly match US commercial general liability, covering injury to third parties and damage to their property arising from your business activities or the products you supply, subject to the policy terms.

Is professional liability the same as professional indemnity?

Broadly, yes. Professional liability and errors and omissions are US terms for cover against claims that your professional services caused financial loss. In the UK this is usually called professional indemnity insurance, although wordings, limits and the basis of cover vary between policies.

Do I need both general liability and professional liability?

Many businesses need both, because they cover different risks. Public liability responds to injury and property damage; professional indemnity responds to financial loss from negligent services. A consultant who visits client sites, for example, faces both kinds of claim.

Can I add a US client as an additional insured on my PI policy?

It is uncommon and needs insurer agreement, because the client is the party most likely to claim against you. Public liability policies more readily extend indemnity to a client. Ask your broker before agreeing to the clause, and offer a certificate showing your cover instead.

Will my UK policy cover a lawsuit filed in the United States?

Not necessarily. Many UK policies exclude or restrict claims brought in US or Canadian courts, or apply lower limits to them. If you work for US clients, ask your broker to confirm the territorial and jurisdiction terms on each policy.

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Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales, company number 07014570. This page is general information, not advice on your individual circumstances, and it does not guarantee that cover will be available or on what terms.